Issuing a Stablecoin: Capital, Reserves and Audits Under the NBG Rulebook

A stablecoin is only as trustworthy as the reserves and controls behind it, and Georgia’s framework is built around exactly that idea. For founders weighing up an issuance, the practical questions are less about the technology and more about money, governance and proof. Get those three right and the licence becomes achievable. Treat them as an afterthought and the application stalls.

Capital comes first. An issuer is expected to be a properly funded company, not a thin shell, and the regulator looks closely at where that capital comes from. Demonstrating clean, well-documented funding is part of showing that the people behind the project are fit to hold customer trust. This is also where many otherwise strong applications run into delay, simply because the paper trail is incomplete.

Reserves are the heart of the model. Tokens in circulation must be fully backed, and the issuer is expected to value the reserve regularly and keep the public informed about its composition. The aim is simple. At any moment, a holder should be confident that the token can be redeemed for the asset it represents, and the issuer should be able to prove it rather than merely assert it.

Independent verification ties the system together. External audit of reserves, carried out on a regular cycle, turns an internal promise into something a regulator and a user can rely on. Alongside that sit technical safeguards, including security testing and continuity planning, because a stablecoin that cannot operate reliably is a stablecoin that cannot meet redemptions when it matters most.

Redemption rights are the user-facing side of all this. Holders are entitled to exchange their tokens at face value, and the issuer is expected to complete that within a short, defined period. Designing operations so that redemptions are routine rather than stressful, even at larger amounts, is a core part of being ready to launch and stay compliant.

Behind the capital and the reserves sits a question the regulator cares about deeply, which is who is actually running the business. Fit and proper management, with relevant experience and clean backgrounds, is part of what persuades the regulator that customer trust is in safe hands. That means thinking early about your directors, your compliance function and the people who will hold significant stakes, because gaps or surprises in this area can stall an otherwise strong application. A stablecoin is, in the end, a promise made by people, and the framework is designed to test whether those people and that organisation can keep it. Building the right team and governance from the outset is as important as funding the reserve, and far harder to retrofit once an application is already under way. Treat the human side of the application with the same rigour you bring to the financial side.

We work with issuers from the earliest structuring decisions through to a complete application, helping shape the entity, the capital position, the reserve policy and the reporting framework into something the regulator will accept. If you are scoping a stablecoin and want a clear picture of what the rulebook asks of you, we are happy to walk you through it before you commit to a path.